RR 1-2014: BIR Amends The Rules On Submission of Alphalist

Under Revenue Regulations 1-2014 (RR 1-2014), all employers are now required to submit a digital copy of the Alphabetical List of their employees and payees. Although the Annual Information Return of Income Taxes Withheld on Compensation and Final Withholding Taxes (Form 1604-CF) and the Annual Information Return Of Creditable Income Taxes Withheld (Expanded)/Income Payments Exempt From Withholding Tax (Form 1604-E) are still going to be filed manually, their attachments or Alphalists should now be digital. This is an amendment of the earlier rule from Revenue Regulations 2-98 as further amended by Revenue Regulations 10-2008.

Here’s the 1998 rule from RR 2-98:

See.2.83.3. Requirement for income payees list. – In lieu of the manually prepared alphabetical list of employees and list of payee’s and income payments subject to creditable and final withholding taxes which are required to be attached as integral part of the Annual Return (Form No. 1604), the Withholding Agent may, at its option, submit computer-processed tapes or cassettes or diskettes, provided that the said list has been encoded in accordance with the formats prescribed by Form 1604.

The above rule was amended in 2008 by RR 10-2008:

Section 2.83.3 Requirement for list of payees – In addition to the manually prepared alphabetical list of employees and list of payees and income payments subject to creditable and final withholding taxes which are required to be attached as integral part of the Annual Information Returns (BIR Form No. 1604CF/ 1604E), Monthly Remittance Returns (BIR Form No. 1601C etc.), the withholding agent may submit soft copy in 3.5- inch floppy diskettes/CD or email: esubmission@bir.gov.ph, containing the said alphalists.

However, taxpayers, whose number of employees or income payees are ten (10) or more, are mandatorily required to submit the said lists in 3.5-inch floppy diskettes/CD or email: esubmission@bir.gov.ph using the existing CSV data file format, together with the manually prepared alphabetical list. In order to comply with this format, the withholding agents shall have the option to use any of the following:

1. Excel format provided under Revenue Regulations No. 7-2000, as amended, following the technical specifications required by the BIR;
2. Their own extract program that shall meet the technical specifications required by the BIR; or
3. Data Entry Module using Visual FoxPro that will be available upon request or by downloading from the BIR’s web site at http://www.bir.gov.ph with the corresponding job aid.

For those who would choose either option 1 or 2, such taxpayers shall use a validation module developed by the BIR, which can be downloaded from the BIR website.

In any case, the withholding agents are required to save the same to a secondary storage as back up for a period of three (3) years from submission of the diskette, as aforementioned, for future reference.

For withholding agents classified as large taxpayers and excise taxpayers falling within the jurisdiction of the Large Taxpayers Service and/or Large Taxpayers District Office, the Annual Information Return of Income Taxes Withheld on Compensation and Final Withholding Taxes (BIR Form No. 1604-CF) and the Annual Information Return of Creditable Income Taxes Withheld (Expanded)/ Income Payments Exempt from Withholding Tax (BIR Form No. 1604-E) shall be submitted to the Large Taxpayers Assistance Division, Large Taxpayers District Offices or Excise Taxpayers Assistance Division, as the case may be. For other withholding agents, the aforesaid annual returns shall be submitted to their respective Revenue District Offices. BIR Form No. 1604-CF shall be submitted on or before January 31 of the succeeding year while BIR Form No. 1604-E shall be filed on or before March 1 of the following year. Only diskettes/CD/email: esubmission@bir.gov.ph readable and virus free files upon submission shall be considered as duly filed “Alphabetical List of Employees/ Payees” by the employer. Violation hereof, shall be a ground for the mandatory audit of violator’s income tax liabilities (including withholding tax). Diskettes/CDs must be uploaded by the abovementioned offices within fifteen (15) days from receipt.

The manually prepared (hard copy for below 10 employees/payees) alphabetical list of employee shall be filed in triplicate copies (two copies for the BIR) to be stamped “received” by the BIR-Large Taxpayers Assistance Division, Large Taxpayers District Office or the Excise Taxpayers Assistance Division, or the Revenue District Office where the payor/employer is registered as Withholding Agent. Manually filed alphalists must be encoded and uploaded by the abovementioned offices within thirty (30) days from receipt.

And now RR 1-2014 sets out the new rule:

Section 2.83.3 Requirement for list of payees – All withholding agents shall, regardless of the number of employees and payees, whether the employees/payees are exempt or not, submit an alphabetical list of employees and list of payees on income payments subject to creditable and final withholding taxes which are required to be attached as integral part of the Annual Information Returns (BIR Form No. 1604CF/1604E) and Monthly Remittance Returns (BIR Form No. 1601C, etc.), under the following modes:

(1) As attachment in the Electronic Filing and Payment System (eFPS);

(2) Through Electronic Submission using the BIR’s website address at esubmission@bir.gov.ph; and

(3) Through Electronic Mail (email) at dedicated BIR addresses using the prescribed CSV data file format, the details of which shall be issued in a separate revenue issuance.

In cases where any withholding agent does not have its own internet facility or unavailability of commercial establishments with internet connection within the location of the withholding agent, the alphalist prescribed herein may be electronically mailed (e-mail) thru the e-lounge facility of the nearest revenue district office or revenue region of the BIR.

The submission of the herein prescribed alphalist where the income payments and taxes withheld are lumped into one single amount (e.g. “Various employees”, “Various payees”, “PCD nominees”, “Others”, etc.) shall not be allowed. The submission thereof, including any alphalist that that does not conform with the prescribed format thereby resulting to the unsuccessful uploading into the BIR system shall be deemed not as received and shall not qualify as a deductible expense for income tax purposes.

Accordingly, the manual submission of the alphabetical lists containing less than ten (10) employees/payees by withholding agents under Annual Information Returns BIR Form No. 1604CF and BIR No. 1604E shall be immediately discontinued beginning January 31, 2014 and March 1, 2014, respectively, and every year thereafter.

In Summary

On specific provisions of the submission of alphabetical list of employees/payees of income payments, here are the changes that took place:

Rule from RR 2-98

All withholding agents are required to submit a manual Alphabetical List.

Amended by RR 10-2008

General Rule – All withholding agents are required to submit manual and digital Alphabetical List.
Exception – If the withholding agent has below 10 number of employees, only manual Alphabetical List is required.

Amended further by RR 1-2014

All withholding agents are required to submit only a digital Alphabetical List.

Comments

Can we apply the new filing system on 2015 instead of this January 2014. This is to enable the employers and filers to be more familiar with the new system. There is lack of information campaign about this latest regulation BIR RR No. 1-2014.
Thank you.

Hi resty. The data that you will submit pertains to 2013 (previous year). About the CSV data file format and the email address you need, you can contact your specific RDO, or you can use the software provided by BIR above to generate the file.

I send the dat file online, and the reply was this:
The BIR has received your data file(s). Please wait for another
notification as your file(s) is/are still subject for validation.
Thank you!
How many hours will the BIR send another notification for the file received?
I’ve been waiting for almost 4 hours.
Thank you.

It wont matter what email add u use, as long as you receive an autoreply from BIR.
Print the autoreply and attached it to the usual forms for 1604cf and 1604e along with the attachments, then still, u need to go to BIR for stamp as received. I was also advice that aside from esubmission@bir.gov.ph, I need to send it to our RDO email address.For rdo 44 email it to rdo044wtalphalist@bir.gov.ph.And another thing, for 2316, all employees must sign their 2316, then you need 4 copies of it. The two copies is for the company and the other two is for BIR, deadline is Feb 28…
Kanina ko lng nalaman ito, when I went to BIR.Hope this helps. Thanks.

If the submission is thru electronic mail, is it like a regular email that you will just attach the file? and if your file is in DAT file format is it the same as csv file? or do i have to format it to csv file?

Hi. I want to ask what format will I write in my email to send the validated 1604cf. I forgot to copy the format. It’s like about the Name of the withholding agent, tin no., adrress, filing reference no. and the optional emails about three(email adress). Need help as soon as possible. Thank you so much.

Hi Sir, I have already submitted the alphalist online with their notification that they have received the file. We went to BIR so they could receive the files (including the printout of notification) but they said they’ll be needing the validation & gave us 15days to go back to them. I’ve made the online submission last Jan. 28 but i still don’t have the validation until now.

Hi Sir, I have already submitted the alphalist online with their notification that they have received the file. e2 po ang lumabas, The BIR has received your data file(s). Please wait for another
notification as your file(s) is/are still subject for validation.
Thank you!

sir ask ko lng if until now i haven’t file yet the 1604CF returns manually due to waiting of validation notification from BIR, i only had their first auto reply na i have to wait for another notification… late na at may penalty na ba kung hinde nai-file kahapon ( feb 3)?…some rdo said kailangan ung validation notice ang dapat i-attach so i have to wait the validation notice b4 filing the returns, some rdo said pwede na daw ung unang notification ( the waiting ) at pag wala kang screen copy nun hinde mo pwedeng i-file at late na… ano po ba talaga ang procedure nila?

Hi marilyn. Yes penalty na if not filed yesterday. The requirement on the email is somewhat RDO specific. There are RDO’s where the email notification receipt is enough for now but they require you to come back for the emailed validation.

good afternoon sir! im using the Alphalist data entry ver 3.4 for 1604-E. there have been 2 applications shown, alphalist data entry ver 3.4 and alphalist validation ver 3.4. Do i have to use the validation apps after finished data entry?

Hello. Is the electronic filing for the monthly 1601E already being implemented? When I asked the collection agent in our RDO last Jan (during the seminar for the electronic filing of the 1604E and 1604CF) he said that there were no implementing rules yet. Thank you.

The moment you installed it, it will ask you to set up a username and password. Once logged in, you can set up another user under Utilities. If you don’t know the initial username and password, just uninstall and install again.

Tried to submit my “manual” 1604-e this morning. Ayaw tanggapin ng BIR. Sa E-Lounge ko na daw gawin. Daming tao. 2 computer lang. Opted to do it at home instead. Found out that I have to register on their website first.

After registering at the ebir website, I received an e-mail entitled “eBIRForms – Account Activation Instructions”. Do I have to submit this along with 2 ids and a Letter of Intent as indicated? Is the Letter of Intent really required? After I submit this printed e-mail tomorrow (impending March 1 1604-e deadline), can I already submit the electronic 1604-e. Are they going to give me my username and password?

Also, I’m worried that the stock 1604-e ATCs might be lacking. Is the patch really needed? Tried running it by placing the exe patch file on the BIRALPHA34 folder and all I’m getting is a RATE error.

hi..may i please know how and where to get the new format of fillable 1601e and 2307 please?? i tried but the new format seems like its not fillable and the old format is..but i need the new ones..please help me